OSHA Changes Ladder Fall Protection Requirements (OSHA 1910.28)

OSHA is on fire! Breaking news! WOW!

Ok now that we’ve got that out of our system… We don’t usually have many changes out there when it comes to OSHA standards but there are some industry changing updates coming that will change a lot of things.

Cages will not be required on fixed ladders after mid November of 2018.

Caged ladders to be phased out for other fall protection options

Caged ladders to be phased out for other fall protection options in 2018

Currently, under OSHA standard 1910.27 cages are required on ladders where the climbs are over 20’h. In OSHA’s new standard (OSHA standard 1910.28) taking effect 11/19/2018, ladders will not be required to have fall protection until their height is over 24’ (24’-0-1/4” requires fall protection). OSHA will also be requiring ladders installed after 11/18/2018 to have fall protection in the form of a personal fall arrest system or ladder safety system (not a cage). If you have cages now, don’t worry, you will be grandfathered in for twenty years.

So, why the change? OSHA is aligning the fixed ladder standard to be more in line with the ANSI standard A14.3, which in 1979 changed its fall protection height requirement from 20’ to 24’.

Why are they telling us now when the rule won’t go into effect until 11/19/2018? OSHA wants to give the industry time to update products and procedures before they go fine crazy. You CAN now follow the new OSHA rule 1910.28 even though it is not in effect yet. You would not be meeting the current OSHA standard, but you would be in compliance with the future OSHA standard. OSHA would consider this a “de minimis violation”. De minimis violations are violations of standards which have no direct or immediate relationship to safety or health, and do not result in a citation, or penalty and need not be abated. 

How does this help you? Well, if your floor to floor height is between 20’ and 24’, you will no longer need to have a cage on your ladder. First off, this can save you LOTS of money. Why?  Not only is it easier to fabricate an uncaged ladder, but there is less steel involved in making the ladder, and also, due to the size a caged ladder takes up on a truck compared to an uncaged ladder, caged ladders can cost 2-4 times as much to ship than their uncaged counterparts.  Another advantage of losing the cage is that you decrease its visibility from the roadside. Without the large cage the ladder is tougher to see from a distance, increasing your buildings visual appeal as well as decreasing the chance that kids looking for a cool place to skateboard, copper thieves, and other people you don’t want on your roof will see the ladder as they pass.

All this being said, when OSHA’s standard mandated cages on climbs over 20’, A-Mezz still offered cages on ladders that only had a climb of 10’ or so and we will continue to offer cages for customers who prefer the added safety of a cage for those shorter climbs. We have gotten feedback from many customers who prefer having a ladder cage because that safety barrier is always in place. You can’t forget to bring a harness with a cage so safety is increased. It is the same argument that makes ladder safety gates so popular and efficient as opposed to ladder chains. Chains only work if the person before you closed them. Ladder safety gates are always in place, always swing closed and always protect you. The same goes for a fixed ladder cage which adds some protection for climbers regardless of whether they have a ladder harness or not.

Face Mounted Mezzanine Gates

Using both a face mounted and deck mouted horizontal sliding mezzanine gate to maximize usable opening space

Face mounted and deck mounted horizontal sliding mezzanine gates

When discussing mezzanine gate projects, a number of customers seem to have some confusion as to what is meant by face mounting a mezzanine gate.  I think in this post, I’ll go over the differences between deck mounting and face mounting and why you might want to mount your gate in such a way.

The vast majority of mezzanine gates are deck mounted.  This means that the gate system sits on top of the mezzanine deck back behind the rail.  Below are a few examples of the various gates we offer mounted to the deck of the mezzanine.
Deck mounted horizontal mezzanine gate

Deck mounted manual horizontal mezzanine gate behind existing hand rail

Stainless steel vertical mezzanine gate attached to the mezzanine deck

Deck mounted stainless steel vertical mezzanine gate.

Occasionally though, the gate is being used in an unusual situation where setting the gate on top of the mezzanine is not an option.  In these cases it might be better to mount the gate outside the mezzanine, attaching it to the face of the platform.  We would call this situation face mounted.
Face mounted mezzanine gate (older design electric horizontal gate)

Electric horizontal mezzanine gate face mounted to the deck

Not all of our mezzanine gates can be mounted to the face of the deck.    The most common gate that we would mount on the face of the mezzanine would be the horizontal sliding mezzanine gate.   As the gate needs to be tied back to your existing railing with clear passage in one direction approximately the length of the opening size plus two feet, pulling the gate outside the deck could help avoid interference with existing equipment up on the mezzanine deck.  In this case, a face mount track would need to be added and attached to the face of the mezzanine just below the opening to support the gate.
vertical electric face mounted mezzanine gate model

Vertical mezzanine gate mounted to the face of the mezzanine

Another gate that can be mounted to the face of the mezzanine is the vertical mezzanine gate.  The vertical mezzanine gate doesn’t take up much room on the deck of a mezzanine, so the applications where you would want to face mount are a bit more specific. Most commonly, this is done in situations where we are mounting an electric vertical mezzanine gate on the outside of a wall opening.  This would allow you to load and unload materials from the deck through a doorway while having a line of guard rail blocking the opening while the doors are open.  Another  situation where face mounting a vertical mezzanine gate might be advantageous, would be in situations where the left column (when viewed from below) would be against some obstruction such as a column.  The left column is the drive column and you’ll want to have it unobstructed just in case you need to access it.  By mounting the gate on the outside of the deck on a couple face mount brackets, the gate flips around placing the drive column on the right side.
Outside view from the bottom of pallet gate mounted around a door frame

Face mounted self closing pallet gate being used to guard a second story doorway.

Another gate that we can do as a face mounted unit would be the self closing pallet gate.  This is typically done in applications where the customer wants to mount the gate on a wall opening.  In such applications, we recommend you still have a second area for offloading the pallets from the deck.  While the self closing pallet gate is incredibly efficient at getting materials up onto the deck, offloading materials from the deck can be cumbersome due to the spring loaded hinges wanting to keep the gate closed.
If you ‘re trying to mount a gate in an unusual situation, perhaps mounting it to the face of the deck might help.  Give us a call, and we’ll be happy to work with you to try and find a solution.

Replacing old dock stairs

We were recently called out to a site with a dock access stair that had seen better days. It got a lot of use, but by the looks of it, had been neglected from a maintenance standpoint. Enamel paint is a great finish if it is maintained, but when left outside around the salt and high traffic to be found on a dock stair it won’t take long to rust without maintenance.

This stair had the painted stair tread nosings all rusted away to a brittle, porous edge. The stringers and support columns all had given way to rust beyond what was fixable with a repair job.

Dock stairs in need of replacement

Dock stairs in need of replacement

The most economical solution for our customer was to have a replacement set of stairs fabricated and hot dipped galvanized. The cost of repair – cutting the current stairs apart, brush/blasting the existing rust out, cutting steel to weld into deteriorated sections, grinding and painting the product –  all in the field would have taken much more time than having replacement stairs fabricated in the shop and brought out to the site. Furthermore we didn’t want to put a “Band-Aid” on the existing stairs by repairing them, knowing the customer wanted to have something in place to forget about. Fabricating a new stair with a hot dipped galvanized would greatly increase the lifespan of the stairs. There is no touch-up painting required and galvanized products can last 5x as long as painted steel.

 

A-Mezz did a site visit to verify conditions and get the existing stair’s measurements. During the visit it was determined that the floor wasn’t completely level. We made the support columns slotted to allow for minor adjustment in the field. This will be more user friendly than making the stair flat and requiring shimming. We didn’t want to fabricate each leg a different length should they one day move it to a new location or have the floor surface refinished in the future.

 

A-Mezz fabricated and pre-assembled as much of the stair and landing as possible in the shop to minimize the time on site with door access out of service as this was a busy dock entrance door. The existing stairs were demo’d and the new stairs were installed in all one morning.

A-Mezz galvanized steel replacement dock stairs

A-Mezz galvanized steel replacement dock stairs

The customer’s new dock stairs will have a long service life due to the hot dipped galvanized finish. The stairs will be able to tackle snow and ice easily with the bar grating treads, and look attractive for years to come – all at a price that was less than repair.

Fixed Ladder Installation – the process from start to finish

A customer called asking for a safe and secure means of accessing their roof and us to do a fixed ladder installation. They have a building that has multiple tenants and didn’t want to have to go through the tenants’ space every time roof access was needed, so an interior ladder and roof hatch combination was off the table. This happens more often than not either because they don’t have a good location inside to mount the ladder or they don’t want to make a hole in their roof.

We went out for a preliminary site visit to verify what the job would entail. The location that was chosen to mount that ladder at was flat from floor to roof. There were no gutters so we would not have to worry about having to either start and stop the gutter and add another down spout, or add a step across platform at the top of the ladder to keep within OSHA’s requirement of a maximum step across a distance of 12”.

Installation site for caged ladder

Installation site for caged ladder

There was a slight parapet at the top of the wall so we set up the extension ladders to verify that the parapet was under 14”high so we would not need to have a crossover ladder with return on the back. We did elect to modify the walk through handrail to remove the return down to the roof to allow more flexibility with installation. Using the self supported walk through handrail allowed a proper fit regardless of the parapet thickness.

Materials were fabricated and shipped to the jobsite where the installation crew attached the lower and upper ladder sections together with the supplied brackets. Next, the ladder was hooked up and elevated into place by a forklift boom. By securing the ladder a little lower than the top, but well past the weight ½ way point, we were able to safely use a shorter, readily available lift and avoid the added cost of additional machine rental.

Lifting the fixed ladder into position

Lifting the fixed ladder into position

The ladder was also outfitted with the LG6 6’ security ladder rung guard to prevent unauthorized access to the ladder. Once hoisted into place, ½” sleeve anchors were inserted into holes drilled into the block and turned until expanded properly, securing the ladder to the wall. For this ladder 18 anchors were used, distributing the 650# ladder and 300# capacity load to well below the tension and shear values for sleeve anchors with the recommended 1-7/8” minimum embedment and a 4:1 (25%) safety factor. Installation was completed in just one morning by a crew of two.

Completed installation of fixed ladder

Completed fixed ladder installation

Installation of the Mezzanine’s IBC Stairs

 

Finished L-shaped external IBC stair

Installed external IBC staircase

Previously, I had written a blog post briefly discussing how to put one of our mezzanines together. It had a lot of good photos taken during the installation, so I was able to go through section by section what was done.  There was one particular area I didn’t get to to over in much detail though; the stairs.  While with the previous system that I wrote about, the customer designed and fabricated their own staircase, I recently received a fantastic series of photos from the installation of another system; this time with partially installed stairs included.

installing the IBC stair

Setting up the stairs

The IBC stairs for or mezzanine systems ship in knock down form and need to be installed in the field.  When installing them, you’ll want to lay the stringers on the floor about 3’ apart with the closed face of the stringers inward.  The diamond tread stair treads consist of a closed back riser and stair tread weldment.  Starting with the top tread and riser, you’ll need to bolt the the tread to the stringer fastening it on the inside of the tread.  Only hand tighten the bolts at this time, then work your way down positioning the riser of the next tread behind the flat weldment of the nose on the tread above.  After all the treads have been attached to the stringers (hand snug) you’ll need to install the bottom riser using self tapping screws.  You’ll then need to hoist the stairs up to the mezzanine deck.  Making sure that the dimension from the top of the deck to the top tread is equal to the dimension between the other treads, you’ll need to field drill the the attachment holes using a 9/16” drill and attach it to the mezzanine system.  You’ll also need to install the top tread plate on top of the mezzanine deck closing off the riser from your first tread.  From the underside, you’ll need to tighten up all the bolts and attach the risers to the back of the above tread’s nose via a couple self tapping screws.  Afterwards you’ll need to anchor the stairs to the ground.

 

Now all that’s left is to finish off the handrail.  The hoops that form the 21” and 36” handrails and handrail extensions come already welded to the stringers.  On each of the uprights, you’ll need to attach an elbow assembly via self tapping screws.  This will provide you with the saddles to support the outer 42” handrail.  You’ll need to take a piece of guardrail pipe for each side, and lay them flush against the saddles, fixing them in place with self tapping screws once again.  As the top line of rail will be longer than the stair run, you’ll want to drop a plumb line from the bottom edge of the rail to the edge of the mezzanine deck and again to the front edge of the bottom stair tread, cutting the pipe square.  Finally, you’ll need to install a plastic plug cap in the openings of the top rail to finish it off.  

Mezzanine Supported Modular Office

Mezzanine with modular office above

Mezzanine supported modular office with a two-wall modular building below

Whether you’re running out of room on the plant floor or need to oversee production, mezzanines are commonly employed to support and elevate modular buildings.  Recently we received some great photos back on a project we completed last month for a mezzanine supported modular office that I thought you might like to see.  The customer was located right here in Northeast Ohio.  They were putting in a new line on the plant floor and needed to tear down some offices they had in order to make room.   There wasn’t enough space to relocate the offices elsewhere on the plant floor, so they decided to utilize some of their unused overhead space.

Side view of mezzanine and modular office.

A 9’ high mezzanine supported modular office with an 8’ high modular wall system below.

When thinking on putting in a mezzanine supported modular building, it’s important to consider just how much space is available.  Remember that with typical column spans in low seismic areas, you’ll probably lose 1’3” to 1’5” for the mezzanine itself.  If you plan on having people move through the area you will need to maintain a minimum of 7’ for clearance.  The modular building panels are typically 8’ or 9’ tall, and unless you are planning on supporting them by the structure above, you will probably want about a foot more in order to install the roof deck to the panels which helps form the membrane that holds the system together.   In this particular case the customer’s mezzanine had a clearance height of 8’7” with a 9’10” top of deck.  This provided us enough room to install a modular office above (9’ tall panels, 9’3-1/8” overall height, 8’6” clearance height) and an 8’ high (8’3-1/8” overall with a 7’6” clear ceiling height) modular wall system below.

inside modular building

Four wall modular office above the mezzanine with customer provided/ installed floor covering

While designing these mezzanine supported modular offices, we’re often asked if we can utilize the adjacent existing walls.  While this is commonly done on the main floor of a facility, unfortunately we cannot do this up on top of the mezzanine deck.   There will always be some movement and vibrations on top of an elevated structure and because of this the structure would need to be a four wall system and not tie into the adjacent walls.  In this particular care, we put in a four wall system above the mezzanine deck as well as a two wall system below the deck to create an enclosed pass way between the production floor, the front offices beyond the cinder block wall, and the production floor entrance way to the outside.

inside view of two wall modular wall system

Two wall modular wall system below the mezzanine

It took our installers 6 work days to unload and install (both mechanical and electrical) the 24’x10’ mezzanine, the 24’x10’ 4-wall modular office above, and the 9’x22’9” two wall modular wall system below, and we had yet another very happy customer.

Now Available, The SafeMezz360 Mezzanine Safety Gate

closed SafeMezz360 mezzanine safety gate

The new SafeMezz360 mezzanine safety gate

It’s an exciting time over in our mezzanine gate division.  Over the next year we will be introducing several new gates to our product line.  Today, I have the pleasure of introducing the first new gate to our regular product line up; the SafeMezz 360 mezzanine safety gate.

Open mezzanine safety gate

The SafeMezz360 mezzanine safety gate open to the edge.

Lately many facilities are opting to follow the voluntary ANSI standards in their workplace.   One area in which ANSI goes above and beyond OSHA would be ANSI MH28.3 Section 6.4.3 requirement that states: “A work platform shall be designed such that the elevated surface is protected by the guards at all times. Gates that swing open, slide open or lift out, leaving an unprotected opening in the guarding, are not acceptable.”   This means that at facilities following the ANSI standards, all pallet openings need to be protected by a true double layered safety gate so that your employees always have a line of guard rail between them and the edge of your deck.

In order to meet these more stringent ANSI requirements, the SafeMezz360 gate utilizes two counter balanced gates which travel on a track up and over your pallets.  Each gate consists of the ANSI required 42” top rail, 21” mid rail, and 4” kick plate. Designed for repetitive use in tough work environments, the SafeMezz 360 is constructed from heavy gauge steel with a durable safety yellow powder coat finish and utilizes an industrial duty chain and sprocket operating system.  The SafeMezz 360 mezzanine safety gate also features a slam proof cushioned dampening system to keep the gate from dropping on your toes.

The SafeMezz 360 is easy to install and operate.  The gates travel smoothly on 2” nylon rollers along it’s track system providing for an easy one-handed operation.  The gate ships in knocked down form for a simple assembly in the field, and bolts easily into place on the mezzanine.

In order to minimize the lead times, we have single and double wide openings available as “quick ship” mezzanine safety gates.  This means that many of the components will be prefabricated and stocked at the factory so that your gate should be ready to ship out in 1-2 weeks. Custom sized safety gates will still be available, but will need to go through full production (typically around 6 seeks after signed approval drawings).

Replace stairs in tight fit locations and meet code

Many locations have old stairs that need to fixed or replaced due to age, damage etc. Generally speaking regardless of the code in place when the original stair was made, you will need to update your stair to the current building code (IBC) when you replace stairs.

OSHA staircase, replace stairs

Stair meeting OSHA standards

3404.1 General. Except as provided by Section 3401.4 or this section, alterations to any building or structure shall comply with the requirements of the code for new construction. Alterations shall be such that the existing building or structure is no less complying with the provisions of this code than the existing building or structure was prior to the alteration.

This becomes an issue when stairs are installed in tight locations under codes that vary greatly from today’s current International Building Code (IBC) variants.

Imagine having a 12’ high stair in place with a riser height of 9” and a tread depth of 9”. This stair would have (16) treads, 9”deep for a total run of 11’3”.

If the replacement stairs would be required to meet IBC code (adopted by all of the states) they would now need to have (20) treads, 11” deep for a total run of 18’4”. The IBC stairs would extend 7’1” further than the originally installed stairs.

The increased run and decreased slope can wreak havoc on your facilities if the original stairs stopped right before a hallway (new stairs would extend well into the hallway) or if the stairs are enclosed (new slope would cause head clearance issues with existing structure).

If the above situation applies to you don’t sweat it. The above referenced IBC code section does have an exception that may help

Exceptions:

  1. An existing stairway shall not be required to comply with the requirements of Section 1009 where the existing space and construction does not allow a reduction in pitch or slope.
  2. Handrails otherwise required to comply with Section 1009.12 shall not be required to comply with the requirements of Section 1012.6 regarding full extension of the handrails where such extensions would be hazardous due to plan configuration.

 

Why the exemption for stairs (and possibly ramps, though not specifically called out)? The thinking behind the exemption is that without it, stairs that need to be replaced and are not safe will be neglected and not maintained due to the inability to bring them up to current codes. It is better to have a well maintained stair meeting an earlier code than have a poorly maintained stair that doesn’t meet current codes.

Removable Access Panel in a Modular Building Equipment Enclosure

cmm room equipment enclosure

New CMM room with removable panel above the door

A very common application for modular buildings is as an equipment enclosure.  The customer is trying to cordon off an area on their production floor to encapsulate a certain process.   Sometimes they are trying to isolate the sound it produces.  Sometimes they are trying to isolate it from a dusty environment.  A lot of these machines, such as CMM machines, won’t fit through a 6’8” or 7’ high doorway.  Once the equipment is in place it usually stays there for many years, but customers often want the ability to get it in and out of the room on rare occasions should the need arise without having to disassemble a good chunk of the building.  For a doorway that will only be used once in a blue moon, it’s rarely cost effective to order a custom swing door, or put in an additional canister style door for equipment access.  A much more cost effective method that we’ve found is to put in a removable access panel.

Removable panel on a modular building

Removable panel above a 6′ x 8′ doorway

Recently, we provided a customer with a modular building to use as an equipment enclosure for their new CMM equipment.  On a day to day basis, a 6’ wide x 6’8” high double door would be more than sufficient for them, but they wanted to be able to occasionally pass something larger through the doorway.   If they were going to pass taller materials through the door way more regularly we could have ordered in a special 8’ high double door, but because they only needed once in a blue moon access we were able save them several hundred dollars in material by putting in a removable panel section above their doorway.  

removable panel drawing

Adding a removable panel is a fairly simple thing to do.  The panels were cut in the factory to accommodate a 6’ wide x 8’ high opening.  We took an additional panel section to cover the gap above the 6’ x 6’8” door and framed it in using the channel for the door frame and some additional “h” cap trim pieces we normally use along the top of the panels.  We also installed “h” cap to the building panels at the opening above the door and fastened the removable panel to the opening.  This sealed off the seams between the panels.  Now when the customer needs that little bit of extra space, all they need to do is remove the screws connecting the panel to the building, allowing them to fit their larger equipment through.

 

 

 

Visiting an Old Mezzanine Supported Modular Office

mezzainine supported modular office from 1997

After almost 20 years of service this modular office is holding up great

Occasionally, I’m asked about how well our modular offices hold up over the years if they are designed so that they can be reconfigured in the future as your needs change.  Surely, after general wear and tear they will want to just order a new building anyway, no?   Well, I recently had the opportunity to visit an old customer of ours.  Over the years, we’ve provided them with a number of mezzanines, catwalks, and modular offices.  Several of the modular offices have been disassembled, modified, and reinstalled in different locations.  While there, I got an opportunity to look at this old tank platform mezzanine and A-wall 300 modular office we provided them with back in 1997.  The steel decking has started to bend up a little at the seam in a couple areas, but after almost twenty years of service the mezzanine and modular office were in excellent condition.  If the customer wanted to, it would still be a simple task to disassemble the modular office and put it up again in a new location, possibly with a few modifications.  The components are all still compatible with what we provide today.  The only design change is that the I-splines used to connect the panels in the A-wall 300 modular building system are now typically painted to match the panels as opposed to the same color as the framing on the windows and doors.  So yes, these modular buildings are built to last.